Schultz reportedly used Help America Vote Act funds for the investigation, which may have violated how the HAVA funds are supposed to be used.

A letter dated Wednesday, December 18, 2013 from the Chief Auditor of State Warren Jenkins said that the HAVA Act doesn’t explain whether it’s permissible to use HAVA funds to investigate potential voter fraud.

In the letter, Jenkins tells Schultz that the funds may be used for activities including educating voters, training election officials, developing state plans, and establishing telephone hotlines to report potential voter fraud.

“However, the Act does not further define “administration of elections”,” Jenkins said. “Section 101 of the Act does not specifically address whether the investigation of complaints and potential criminal activity is an allowable expenditure under HAVA.”

According to a statement by Schultz, he stands by his actions.

“As I’ve said all along, the use of HAVA funds for a DCI investigator to investigate voter fraud in Iowa has been proper,” Schultz said. “The investigation has helped the administration of federal elections in Iowa by helping ensure the integrity of votes cast by Iowans.”

According to Jenkins’ letter, by June 2013 the Secretary of State had used more than $100,000 of HAVA funds for the investigation.

WHO reported that as of December 2013, charges have been brought against 16 people in relation to the investigation.

According to a spokesperson from the Auditor’s Office, the Secretary of State was advised to figure out a way to repay the funds in case the Commission requests repayment.